IRS Proposal Would Require Businesses to Report Uncertain Tax Positions Directly on Returns
IRS Commissioner Shulman shocked most tax preparers and professionals last week at a New York State Bar Association Tax Section Meeting when he proposed that businesses should be required to provide detailed information in their tax returns regarding uncertain tax positions taken on their returns. Under the Commissioner’s proposal, taxpayers would be required to provide a “few sentences” of information explaining the nature of each uncertain tax position, and taxpayers who fail to disclose these “uncertain tax positions” would be subject to significant penalties.
If it sounds like the Commissioner is asking taxpayers to do the IRS’s job for them, you are at least partially right. The Commissioner is concerned that the IRS is spending too much time attempting to identify tax issues and believes that requiring the disclosure of uncertain positions will enable the IRS to resolve these issues much more quickly and efficiently than it is doing right now.